🇪🇺EU Citizenship Routes: Naturalization, Investment, Descent

🧭 New: birthright citizenship — where to give birth — an interactive picker across 12 countries: jus soli, the EU's conditional routes, parental perks and traps like the US tax tail.

Concept

An EU passport grants the right to live, work, and do business across twenty-seven member states, and demand for it stays high. There are essentially three routes: naturalization after several years of residence, investment through a residence permit, and descent. Each has its own horizon and its own price, and over the past two years the rules have tightened noticeably — a realistic route is worth mapping in advance against residence periods, the language bar, and the cost of the investment.

Naturalization: Counted in Years

The most common path is to live in a country lawfully for a set period and then apply for citizenship. France and Germany require five years: in autumn 2025 Germany scrapped the accelerated three-year route it had introduced only a year earlier, and from 1 November 2025 the baseline five-year requirement remained. Spain formally asks for ten years but cuts it to two for nationals of Latin America, Andorra, the Philippines, Equatorial Guinea, and Portugal, and for descendants of Sephardic Jews. Almost everywhere you must genuinely live in the country — around 183 days a year — and prove the language: from 1 January 2026 France raised the bar from B1 to B2 in both speaking and writing.

Investment: First Residence, Then Naturalization

Portugal's and Greece's golden visas grant a residence permit in exchange for an investment, but the investment itself does not grant a passport. Residence only starts the naturalization clock, and this is where the rules shifted the most. In spring 2026 Portugal carried out a reform that raised the qualifying period from five years to seven for citizens of the EU and Portuguese-speaking countries (CPLP) and to ten for everyone else: the law passed parliament in April and was signed by the president in May 2026 after review by the Constitutional Court, and the clock now runs from the moment the residence card is issued. The one direct route to a passport in exchange for investment remained Malta's, but after the EU Court of Justice's ruling of 29 April 2025 in case C-181/23 the sale of citizenship was found contrary to EU law, leaving only naturalization for exceptional merit.

How Much Entry Costs

The figures for the two main golden visas are worth keeping in mind. Since autumn 2024 Greece has split its thresholds by region: €800,000 for property in Athens, Thessaloniki, and popular islands such as Mykonos and Santorini, €400,000 in other areas, and €250,000 for converting a commercial property into housing or restoring a listed building. Portugal closed real estate to the golden visa back in October 2023 under the Mais Habitação reform: entry now runs through an investment of at least €500,000 into CMVM-regulated funds or a donation from €250,000 to culture and science. The residence card comes quickly, but the road to a passport still runs through years of naturalization.

Descent: Only for Certain Families

A number of EU states recognize citizenship by descent where ancestors were their nationals, but this window is narrowing too. Italy, traditionally the most generous, limited jus sanguinis to two generations by Law No. 74/2025 (following the decree of 28 March 2025) — a parent or grandparent must have been born in Italy — and now requires a genuine connection to the country; citizenship through great-grandparents is no longer recognized. Ireland still grants a passport to those with a grandparent born on the island, through the Foreign Births Register. Conditions vary widely from country to country and suit a narrow circle of families with a documented lineage, so for most high-net-worth clients without such roots the practical choice comes down to naturalization and investment routes.

What the EU Court's Malta Ruling Changes

Case C-181/23 closed an entire era. The EU Court of Justice held that granting citizenship in exchange for a predetermined payment without a genuine connection to the state turns citizenship into a commodity and breaches Article 20 of the Treaty on the Functioning of the EU and the principle of sincere cooperation. Formally, citizenship remains a competence of the member states, but since it also confers Union citizenship, that competence must be exercised in accordance with EU law. For the market this is a signal to every country: direct passport-sale schemes inside the EU will no longer pass, and investment programmes will have to be built around genuine residence and integration.

How to Choose a Route

The choice comes down to four parameters. Horizon: naturalization means five years at best and up to ten in Spain or the reformed Portugal. Presence: almost every country expects genuine residence of around 183 days a year, not a formal address. Language: the bar is rising, and France's B2 requirement from 2026 is a vivid example. Taxes: relocation almost always makes you a tax resident, so regimes such as Cyprus's non-dom or Portugal's IFICI are worth mapping in advance. The fate of your prior citizenship is planned separately — renouncing it and a possible exit tax.

Wealthy families increasingly build the plan in two steps: first a predictable residence permit in a country with a clear tax regime, then naturalization as the qualifying period accrues. That turns a seven-to-ten-year horizon into a manageable schedule and leaves room for the rule changes that have become the norm in recent years.

This material is expert-analytical in nature and does not constitute individual legal or tax advice.

Sources

• C-181/23